| Moderator: | J. Clark Armitage |
| Program: | The APA Landscape: How APAs Are Affected by "Eaton" and U.S. Tax Reform |
| Event Sponsor: | TP Minds Americas |
| Where: | Biltmore Hotel - Miami
1200 Anastasia Avenue
Coral Gables, FL 33134
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| Registration: | Click Here To Register |
The panel will address how the Tax Court’s Eaton decision affects the enforceability of APAs, as well as its impact on preparing submissions and compliance. The panel will discuss:
- Whether the IRS may enforce an APA against the APA taxpayer
- The burden of proof in cases involving an attempted rescission of an APA
- Whether taxpayers’ obligations to provide an accurate and complete submission have changed; and
- How to handle compliance issues in the APA Annual Report process.